0120110924
10-09-2012
John J. Schulz, Complainant, v. Patrick R. Donahoe, Postmaster General, United States Postal Service (Northeast Area), Agency.
John J. Schulz,
Complainant,
v.
Patrick R. Donahoe,
Postmaster General,
United States Postal Service
(Northeast Area),
Agency.
Appeal No. 0120110924
Agency No. 4B-100-0035-10
DECISION
Complainant timely filed an appeal from the Agency's November 2, 2010, final decision concerning his equal employment opportunity (EEO) complaint alleging employment discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. � 2000e et seq. The Commission accepts the appeal pursuant to 29 C.F.R. � 1614.405(a). For the following reasons, the Commission AFFIRMS the Agency's final decision.
ISSUE PRESENTED
The issue presented is whether the Agency properly found that Complainant failed to prove that the Agency subjected him to discrimination and harassment on the bases of race and reprisal.
BACKGROUND
At the time of events giving rise to this complaint, Complainant worked as a Supervisor, Customer Service, at the Agency's Cathedral Station in New York, New York.
On April 23, 2010, Complainant filed an EEO complaint alleging that the Agency discriminated against him and subjected him to harassment on the bases of race (Caucasian) and reprisal for prior protected EEO activity when:
1. on December 23, 2009, Complainant was given a Pre-Disciplinary Interview (PDI), which resulted in him being issued a Notice of Proposed Letter of Warning in lieu of 14-Day Suspension on February 2, 2010, for Insubordination/Abandonment of Supervisory Assignment;
2. on unspecified dates, Complainant was denied annual leave;
3. on January 11, 2010, Complainant was harassed and yelled at to get off the computer;
4. on February 5, 2010, Complainant was denied issuance of a locker and keys to the 3rd floor supervisors' swing room;
5. on unspecified dates, Complainant was threatened with AWOL and required to bring in documentation for his absences;
6. on February 13, 2010, Complainant's tour of duty was changed from 3:00 a.m. - 11:30 a.m. to 9:00 a.m. - 6:00 p.m.;
7. on February 23 2010, Complainant's overtime was disallowed; and
8. on February 23, 2010, Complainant was berated, threatened with discipline, and instructed to "hit off the clock."
Allegations 1 and 2: Letter of Warning and Denial of Annual Leave
In December 2009, Complainant was assigned to work a 3:00 a.m. - 11:30 a.m. tour of duty. Complainant worked from 2:00 a.m. - 6:29 a.m. on December 1, from 1:46 a.m. - 6:25 a.m. on December 2, from 1:15 a.m. - 6:32 a.m. on December 3, and from 11:42 a.m. - 4:57 a.m. on December 4, 2009. Report of Investigation (ROI) Exhibit (Ex.) 6. He did not submit leave slips for December 1 and 2 because, according to Complainant, his immediate supervisor (S1) has inputted leave for him in the past. Id. Affidavit (Aff.) A at 15. Complainant asserts that, on December 4, he submitted leave slips for December 3 and 4 to the Manager of Customer Services (S2), that S2 marked the December 3 slip "notified only," and that S2 disapproved the December 4 request on basis of "services needed." Id. at 18. Complainant also asserts that he came to work early on December 1, 2, 3, and 4 because S2 had ordered some of Complainant's subordinates to come to work early on those days. Id. at 16.
In a December 4, 2009, letter addressed "To whom it may concern," S2 stated that Complainant left work early on December 1 after telling S2 that S1 was aware he was leaving and that S1 usually gave Complainant annual leave. According to the letter, S1 later told S2 that he had not approved leave for Complainant. The letter also stated that Complainant abandoned his assignment and left the building early on December 3, that Complainant asked S2 to approve leave requests for December 3 and 4 on December 4, that S2 replied that he would not approve Complainant's requests because Complainant's service was needed, and that Complainant abandoned his assignment and left the building early on December 4. The Manager of Customer Services Operations (S3) forwarded the letter to the Agency's Office of Inspector General (OIG), which investigated the matter. S1 and S2 told OIG agents that Complainant had left work early to attend training classes to become a corrections officer. Complainant acknowledged to the agents that he was in training and had left work without permission, but he did not admit that he did so to attend training. Id. Ex. 7.
S1 conducted a Pre-Disciplinary Interview with Complainant on December 26, 2009, and issued Complainant a Notice of Proposed Letter of Warning in Lieu of 14-Day Suspension for Insubordination/Abandonment of Supervisory Assignment on February 2, 2010. Id. Exs. 4, 5. In the Notice, S1 stated that Complainant altered his schedule and left work without permission on December 1 through 4, 2009. S1 also stated that Complainant was insubordinate when he did not comply with S2's denial of his leave request on December 4, 2009.
Complainant asserted that the Agency treated him less favorably than it treated African-American supervisors. According to Complainant, a Supervisor of Customer Services (C1) who received two weeks of annual leave in November 2009 was caught falsifying time records but not disciplined. He asserted that, in November and December 2009, S1 and S2 allowed the Manager of Customer Services (C2) to take seven weeks off to work a second job, a Customer Services Analyst (C3) received one week of annual leave, and a Customer Services Supervisor (C4) who continually began his tour early received five days of annual leave. Complainant also asserted that a Customer Services Supervisor (C5) was absent without leave (AWOL) twice but not cited and a different Customer Services Supervisor (C6) continuously arrived late. Id. Aff. A; Formal Complaint at 7
In addition, Complainant asserted that S2 did not contact OIG when S1 and C1 were caught falsifying time records. Complainant's affidavit includes a copy of a December 30, 2009, Notice of Proposed Letter of Warning in Lieu of Seven-Day Suspension for Failure to Perform Managerial Duties that S2 issued to S1. The Notices stated that there were irregular clock rings in November 2009, that S1 believed that the irregularities were connected to a certain supervisor, that S1 failed to follow up on his investigation with the supervisor, and that S1 told S2 that he would conduct a PDI with the supervisor. According to the PDI notes for the Notice, C1 was the supervisor believed to be connected to the irregular clock rings. ROI Aff. A at 8, 31-33.
With respect to Complainant's assertions that the Agency approved other supervisors' leave requests, S1 told the EEO Investigator that there was no truth to Complainant's statements. S2 told the Investigator that C1 receive special consideration because he was preparing for military deployment. S2 also told the Investigator that he was not at the facility when C2 worked there and that he approved one week of leave for C3 because she transferred to another district and her vacation would not affect the Cathedral Station's operations. S2 stated that he approved C4's start time, that he had no problem with C4's hits, and that, unlike C4, Complainant swiped his badge before his tour began to show four hours of work before his departure. In addition, S2 stated that C5 was charged with being AWOL once and that the charge was rescinded because of the Agency's religious accommodation obligations. With respect to C6, S2 stated that a supervisor's late arrival within the half hour is not a problem because supervisors work longer than eight hours and work through lunch. S3 told the Investigator that C2 did not have a second job. Id. Affs. B at 5-6, 9-11, C at 8-10, D at 5.
Allegation 3: January 11, 2010, Incident
Complainant asserted that, on January 11, 2010, S2 instructed S1 to tell him to get off the computer. He claimed that S1 stood over him and yelled at him to get out of the chair, tried to grab his elbow, and berated him in front of the clerks and carriers. Formal Complaint at 4. S1 stated that he yelled because Complainant claimed he could not hear S1. ROI Aff. C at 5. S2 stated that he could not recall giving S1 those instructions. Id. Aff. C at 6.
Allegation 4: Locker and Keys to Supervisors' Swing Room
According to Complainant, S1 and S2 provided African-American supervisors with lockers in the registered mail cage and keys to the swing room but did not provide Complainant with those items. Id. Aff. A at 6. S1 stated that Complainant did not request a locker or show any interest in receiving keys to the swing room, and S2 stated that Complainant did not ask him about lockers or keys. Id. Affs. B at 6, C at 6.
Allegation 5: AWOL Threat
Complainant asserted that S2 constantly requested documentation for his Family and Medical Leave Act (FMLA) absences and threatened to place him on AWOL. Formal Complaint at 8; ROI Aff. A at 6. S2 told the EEO Investigator that he did not threaten Complainant with AWOL. According to S2, he may have once told Complainant that administrative documentation was required and failure to provide the documentation would result in Complainant being AWOL. ROI Aff. B at 7.
Allegation 6: Tour of Duty
By memorandum dated February 13, 2010, S2 informed Complainant that his tour of duty would change from 3:00 a.m. - 11:30 a.m. to 9:00 a.m. - 2:00 p.m. because of his irregular attendance and failure to make the scheduled "F4 Up-Time." Formal Complaint at 16. Complainant asserted that he was making his F4 Up-Times and that C4 replaced him. Id. at 8; ROI Aff. A at 7. S2 asserted that he made the change because Complainant's attendance was irregular, Complainant could not be relied upon to be in the office at 3:00 a.m., and he needed to put Complainant on a tour where he could supervise him. S2 also asserted that he replaced Complainant with a supervisor who would be at work at 3:00 a.m. ROI Aff. B at 7.
Allegation 7: Denial of Overtime for EEO Activity
On February 23, 2010, S2 disallowed Complainant's use of overtime. Complainant asserted that S2 told him he was not allowed to work overtime for any EEO activity. Id. Aff. A at 7. S2 stated that he saw Complainant typing on the computer at his desk and noticed the next day that Complainant had incurred overtime. He stated that he disallowed the overtime claim because Complainant was not supervising three or more employees, his tour had ended, and he was not authorized to extend his tour. Aff. B at 7. S1 stated that Complainant was typing a document about his harassment allegations, that it was not job related, and that the Agency "would not allow him to make out any statement about his alleged harassment on the clock." Id. Aff. C at 7.
Allegation 8: February 23, 2010, Incident
On February 23, 2010, S2 gave work instructions to Complainant. Complainant asserted that he told S2 he needed to be trained properly, S2 instructed him to work with C1 in another section, he questioned S2 about the instruction, S2 berated him and created a scene on the workroom floor, and S2 told S1 to hit Complainant off the clock and discipline him. Formal Complaint at 11. S2 asserted that he instructed Complainant to work with the carriers, Complainant told him he was not supposed to work with carriers, and he told Complainant that failure to follow the instruction would result in him taking Complainant off the clock. ROI Aff. B at 8.
Complainant's Prior EEO Activity
Complainant stated that he engaged in prior EEO activity when he started an EEO case, number PRE-005048-2010, against C2 on November 18, 2009. His affidavit includes a copy of a November 19, 2009, letter acknowledging his request for pre-complaint counseling and providing forms for him to submit to the Agency's EEO Contact Center. Complainant asserted that he told S3 about the complaint on December 5, 2009, that S3 told Complainant he would not win, that Complainant dropped the complaint because S3 said he would cover Complainant for two weeks if Complainant dropped the case, and that Complainant was not charged with AWOL for the two weeks. The request for counseling does not appear in the Agency's iComplaints information. Complainant contacted an EEO Counselor about the instant complaint on January 11, 2010. S1, S2, and S3 told the EEO Investigator that they were not aware of Complainant's EEO activity. Id. Affs. A at 3, 41, B at 2, C at 3, D at 2; Ex. 2; EEO Counselor's Report at 1.
Final Agency Decision
At the conclusion of the investigation, the Agency provided Complainant with a copy of the report of investigation and notice of his right to request a hearing before an EEOC Administrative Judge (AJ). In accordance with Complainant's request, the Agency issued a final decision pursuant to 29 C.F.R. � 1614.110(b). The decision concluded that Complainant failed to prove that the Agency subjected him to discrimination as alleged.
In its final decision, the Agency found that Complainant did not establish a prima facie case of race or reprisal discrimination. The Agency concluded that the comparators Complaint cited were not similarly situated to Complainant because, although they were supervisors, they supervised different operations, worked at different times, and performed different functions. The Agency found that Complainant engaged in protected activity when he filed the instant complaint but concluded that he had not shown a causal link between the activity and the adverse actions at issue. In that regard, the Agency stated that managers were not aware of the current complaint when they took the actions. In addition, the Agency found that management articulated legitimate, nondiscriminatory reasons for the actions and Complainant did not demonstrate that the reasons were pretextual.
With respect to Complainant's harassment claim, the Agency found that the discrete acts about which Complainant complained were issues that normally arise in an employment setting rather than harassing conduct. The Agency also found that there was no evidence that the acts were related to Complainant's race or prior EEO activity. Further, the Agency concluded that there was no basis for imputing liability to the Agency because Complainant did not complain to management that he was being subjected to discriminatory harassment.
CONTENTIONS ON APPEAL
The parties raise no new arguments on appeal.
STANDARD OF REVIEW
As this is an appeal from a decision issued without a hearing, pursuant to 28 C.F.R. � 1614.110(b), the Agency's decision is subject to de novo review by the Commission. 29 C.F.R. � 1614.405(a). See Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614, at Chap. 9, � VI.A. (Nov. 9, 1999) (explaining that the de novo standard of review "required that the Commission examine the record without regard to the factual and legal determination of the previous decision maker," and that EEOC "review the documents, statements, and testimony of record, including any timely and relevant submissions of the parties, and ... issue its decision based on the Commission's own assessment of the record and its interpretation of the law").
ANALYSIS AND FINDINGS
Disparate Treatment
To prevail in a disparate treatment claim, Complainant must satisfy the three-part evidentiary scheme fashioned by the Supreme Court in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Complainant must initially establish a prima facie case by demonstrating that he was subjected to an adverse employment action under circumstances that would support an inference of discrimination. Furnco Construction Co. v. Waters, 438 U.S. 567, 576 (1978). Proof of a prima facie case will vary depending on the facts of the particular case. McDonnell Douglas, 411 U.S. at 802 n. 13. The burden then shifts to the Agency to articulate a legitimate, nondiscriminatory reason for its actions. Texas Dep't of Community Affairs v. Burdine, 450 U.S. 248, 253 (1981). To ultimately prevail, Complainant must prove, by a preponderance of the evidence, that the agency's explanation is pretextual. Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 143 (2000); St. Mary's Honor Center v. Hicks, 509 U.S. 502, 519 (1993).
We assume for purposes of analysis, without so finding, that Complainant has established prima facie cases of discrimination based on race and reprisal. Further, as explained below, we find that the agency articulated legitimate, nondiscriminatory reasons for its actions and that Complainant failed to establish that the reasons were pretexts for discrimination.
Allegations 1 and 2: Letter of Warning and Denial of Annual Leave
The Notice of Proposed Letter of Warning in Lieu of 14-Day Suspension for Insubordination/Abandonment of Supervisory Assignment stated that Complainant altered his schedule and left work without permission on December 1 through 4, 2009. It also stated that Complainant was insubordinate because he did not comply with S2's denial of his request for leave on December 4, 2009. S2 stated that he denied the request because Complainant's services were needed.
Complainant has not shown these reasons to be pretexts for discrimination. Complainant asserts that other supervisors were treated more favorably, but there is no evidence that the other supervisors took non-emergency leave without submitting leave slips in advance. Further, there is no evidence that they left work even though their leave requests were denied. Although the record indicates that C1 received favorable treatment, the evidence establishes that he received special consideration because he was preparing for military deployment in support of Operation Iraqi Freedom. The other comparators were not similarly situated to Complainant. For example, S3 denied that C2 had a second job, C3's request for annual leave was approved because she transferred to another district, and C5's AWOL charge was removed in light of the Agency's religious accommodation obligations. The evidence does not support Complainant's assertion that he was treated less favorably than others because of his race or prior EEO activity.
Allegation 3: January 11, 2010, Incident
S1 stated that he yelled at Complainant because Complainant claimed he could not hear S1. There is no evidence in the record to refute S1's statement. Similarly, there is no evidence that S1's conduct was motivated by considerations of Complainant's race or prior EEO activity.
Allegation 4: Locker and Keys to Supervisors' Swing Room
S1 and S2 stated that Complainant did not ask them for a locker or keys to the swing room. Complainant has not shown the statements to be pretexts for discrimination. For example, he has not shown that he in fact requested a locker and keys to the swing room or that similarly situated employees received those items without requesting them. Accordingly, he has not established that the Agency denied him a locker and keys to the swing room because of his race or prior EEO activity.
Allegation 5: AWOL Threat
S2 stated that he told Complainant that documentation was required for his absences and failure to produce documentation would result in Complainant being AWOL. There is no evidence that S2 made these statements to Complainant because of Complainant's race or prior EEO activity. For example, there is no evidence that other employees whose use of FMLA leave was similar to Complainant's were not required to produce supporting documentation. Complainant has not shown that S2's statements were discriminatory.
Allegation 6: Tour of Duty
S2 stated that he changed Complainant's tour of duty because Complainant's attendance was irregular and he could not rely on Complainant to be at work at 3:00 a.m. Although Complainant notes that C4, an African-American supervisor with no prior EEO activity, replaced him, he has not shown S2's explanation to be pretextual. The record establishes that Complainant left work early on December 1 through 3, 2009, without receiving advanced approval, left work on December 4, 2009, after C2 denied his request for leave, and frequently clocked in before 3:00 a.m.
Allegation 7: Denial of Overtime for EEO Activity
Complainant alleged that S2 told him that he was not allowed to work overtime for any EEO activity. S2 stated that he saw Complainant typing on the computer, noticed the next day that Complainant had incurred overtime, and disallowed the overtime because Complainant was not supervising employees and was not authorized to extend his tour. S1 stated that Complainant was typing a document about his harassment allegations, that it was not job related, and that the Agency would not allow Complainant to prepare a statement about his harassment allegations on the clock.
EEOC Regulation 29 C.F.R. � 1614.605(b) provides that, if the complainant is an employee of the agency, he or she shall be given a reasonable amount of official time, if otherwise on duty, to prepare an EEO complaint and to respond to agency and EEO requests for information. The Commission has stated that an allegation pertaining to the denial of official time states a separately processable claim alleging a violation of the Commission's regulation, without requiring a determination of whether the action was motivated by discrimination. See Edwards v. U.S. Postal Serv., EEOC Request No. 05960179 (Dec. 23, 1996). Essentially, the Commission has held that it has the authority to remedy a violation of 29 C.F.R. � 1614.605 without a finding of discrimination. Id. The Commission held that such a claim should not be processed in accordance with 29 C.F.R. � 1614.108, because the focus is not on the motivation, but rather the justification of why the complainant was denied a reasonable amount of official time. Id.
In this case, there is no evidence that Complainant requested official time to work on his EEO matters prior to doing such work and incurring overtime. In the absence of such evidence, we cannot say that the Agency violated the Commission's regulations. We remind the Agency, however, that it has an obligation to provide employees with a reasonable amount of official time to work on EEO matters. Contrary to S1's assertion, the Agency must provide complainants with a reasonable amount of time to prepare statements regarding allegations of harassment and other discriminatory practices. We advise the Agency to ensure that all of its managers are aware of their obligations under EEOC regulations.
Allegation 8: February 23, 2010, Incident
S2 stated that he instructed Complainant to work with the carriers, Complainant objected, and S2 told Complainant that he would be taken off the clock if he failed to follow instructions. Complainant has not shown that S2's actions were discriminatory. For example, Complainant has not shown that similarly situated supervisors not of his protected group were allowed to ignore instructions or that discriminatory animus motivated S2's conduct.
Harassment
In Harris v. Forklift Systems, Inc., 510 U.S. 17, 21 (1993), the Supreme Court reaffirmed the holding of Meritor Savings Bank v. Vinson, 477 U.S. 57, 67 (1986), that harassment is actionable if it is "sufficiently severe or pervasive to alter the conditions of [complainant's] employment and create a hostile or abusive working environment." The Court explained that an "objectively hostile or abusive work environment [is created when] a reasonable person would find [it] hostile or abusive" and the complainant subjectively perceives it as such. Harris, 510 U.S. at 21-22. Whether the harassment is sufficiently severe to trigger a violation of Title VII must be determined by looking at all the circumstances, including "the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee's work performance." Id. at 23.
To establish a claim of harassment based on race or reprisal, Complainant must show that: (1) he is a member of the statutorily protected class; (2) he was subjected to harassment in the form of unwelcome verbal or physical conduct involving the protected class; (3) the harassment complained of was based on his statutorily protected class; (4) the harassment affected a term or condition of employment and/or had the purpose or effect of unreasonably interfering with the work environment and/or creating an intimidating, hostile, or offensive work environment; and (5) there is a basis for imputing liability to the employer. Humphrey v. U.S. Postal Serv., EEOC Appeal No. 01965238 (Oct. 16, 1998); 29 C.F.R. � 1604.11. Further, the incidents must have been "sufficiently severe or pervasive to alter the conditions of [Complainant's] employment and create an abusive working environment." Harris, 510 U.S. at 21. The harasser's conduct should be evaluated from the objective viewpoint of a reasonable person in the victim's circumstances. Enforcement Guidance on Harris v. Forklift Systems, Inc., EEOC Notice No. 915.002 (Mar. 8, 1994) (Enforcement Guidance on Harris). The evaluation "requires careful consideration of the social context in which particular behavior occurs and is experienced by its target." Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75, 81 (1998). The anti-discrimination laws are not a "general civility code." Id.
In this case, the record does not support a finding that the Agency subjected Complainant to discriminatory harassment. As noted above, the evidence does not establish that the incidents alleged by Complainant occurred because of his race or prior EEO activity. A finding of discriminatory harassment is precluded based on our determination that Complainant failed to show that the Agency's actions were motivated by discriminatory animus. See Oakley v. U.S. Postal Serv., EEOC Appeal No. 01982923 (Sept. 21, 2000). Accordingly, we find that Complainant has not demonstrated that the Agency discriminated against him on the basis of race or reprisal.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal, including those not specifically addressed herein, we AFFIRM the Agency's final decision and its finding of no discrimination.
STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M0610)
The Commission may, in its discretion, reconsider the decision in this case if the Complainant or the Agency submits a written request containing arguments or evidence which tend to establish that:
1. The appellate decision involved a clearly erroneous interpretation of material fact or law; or
2. The appellate decision will have a substantial impact on the policies, practices, or operations of the Agency.
Requests to reconsider, with supporting statement or brief, must be filed with the Office of Federal Operations (OFO) within thirty (30) calendar days of receipt of this decision or within twenty (20) calendar days of receipt of another party's timely request for reconsideration. See 29 C.F.R. � 1614.405; Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO MD-110), at 9-18 (Nov. 9, 1999). All requests and arguments must be submitted to the Director, Office of Federal Operations, Equal Employment Opportunity Commission, P.O. Box 77960, Washington, DC 20013. In the absence of a legible postmark, the request to reconsider shall be deemed timely filed if it is received by mail within five days of the expiration of the applicable filing period. See 29 C.F.R. � 1614.604. The request or opposition must also include proof of service on the other party.
Failure to file within the time period will result in dismissal of your request for reconsideration as untimely, unless extenuating circumstances prevented the timely filing of the request. Any supporting documentation must be submitted with your request for reconsideration. The Commission will consider requests for reconsideration filed after the deadline only in very limited circumstances. See 29 C.F.R. � 1614.604(c).
COMPLAINANT'S RIGHT TO FILE A CIVIL ACTION (S0610)
You have the right to file a civil action in an appropriate United States District Court within ninety (90) calendar days from the date that you receive this decision. If you file a civil action, you must name as the defendant in the complaint the person who is the official Agency head or department head, identifying that person by his or her full name and official title. Failure to do so may result in the dismissal of your case in court. "Agency" or "department" means the national organization, and not the local office, facility or department in which you work. If you file a request to reconsider and also file a civil action, filing a civil action will terminate the administrative processing of your complaint.
RIGHT TO REQUEST COUNSEL (Z0610)
If you decide to file a civil action, and if you do not have or cannot afford the services of an attorney, you may request from the Court that the Court appoint an attorney to represent you and that the Court also permit you to file the action without payment of fees, costs, or other security. See Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. � 2000e et seq.; the Rehabilitation Act of 1973, as amended, 29 U.S.C. �� 791, 794(c). The grant or denial of the request is within the sole discretion of the Court. Filing a request for an attorney with the Court does not extend your time in which to file a civil action. Both the request and the civil action must be filed within the time limits as stated in the paragraph above ("Right to File a Civil Action").
FOR THE COMMISSION:
______________________________
Carlton M. Hadden, Director
Office of Federal Operations
October 9, 2012
Date
2
0120110924
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
2
0120110924